TABLE 8.1 Assignment of Tasks for Waste Handling


Task

Who Should Perform

Why?


Determine if waste is regulated as hazardous

Staff

Knowledge of the waste, liability considerations, and economics

Segregate according to hazard class

Staff

Economics and safety in storage

Determine if the material will be recycled or reused

Staff

Economics, knowledge of in-house requirements and capabilities

Commingling if appropriate

Staff

Economics, safety, liability, storage space; waste disposal firm could be consulted for advice

Determine appropriate disposal method

Staff and employees of the waste disposal firm

Waste disposal firm is aware of options for Specific waste streams; staff should be involved because of liability and cost

Determine packing protocol for labpacks

Waste disposal firm

The waste disposal firm is aware of what is required by the treatment, storage, and disposal facility

Labpacking

Waste disposal firm

The waste disposal firm is generally required to do labpacking

Manifest preparation

Waste disposal firm; review by Staff

The waste disposal firm typically has more experience and will prepare the manifest; staff should be properly trained in how to review a manifest because of liability and cost considerations


This fgure does not apply to surplus chemicals held for redistribution to other laboratories.

8.B.4.3 Special Regulations for Laboratories at Academic Institutions

Although laboratories are generally required to comply with the same regulations as industrial facilities, regulations promulgated in 2008 provide limited relief for academic institutions from some of the requirements associated with on-site management. When adopted by the state in which the laboratory is located, these alternative standards are available to colleges, universities, teaching hospitals, and certain nonprofit research facilities associated with colleges or universities. These standards are completely optional, at the discretion of the educational or research institution. To take advantage of these provisions, academic facilities must implement a performance-oriented laboratory management plan. This facility-specific plan must provide for seven required elements:

1.   labeling standards,

2.   container standards,

3.   training requirements,

4.   removal frequency of unwanted chemicals,

5.   hazardous waste determinations,

6.   laboratory cleanouts, and

7.   prevention of emergencies.

The provisions allow academic facilities additional time to move waste from laboratories to central accumulation areas and additional time and flexibility in making waste determinations, and encourage laboratory cleanouts by providing relief from some time limits and generator classification provisions. However, these alternative standards require semiannual removal of all laboratory hazardous waste, whereas the standard satellite accumulation rule has no time limit for the accumulation of laboratory waste in unfilled containers smaller than 55 gal.

The academic waste rule does not apply in states with primacy over RCRA regulations until promulgated by the state. Check with your state environmental agency to see if the rule has been implemented. The entire text of the rule is available at the EPA Web site, www.epa.gov.

8.B.5 Disposal of Nonhazardous and Nonregulated Waste

Some nonregulated laboratory waste is hazardous and should be safely managed. There are more waste management options for nonregulated waste, especially with regard to hazard reduction procedures.

Some laboratories have policies that require all chemical waste to be handled as if it were regulated as hazardous. This recognizes the potential liabilities associated with misperceptions or the improper handling of nonregulated as well as regulated waste. For example, a trash hauler or landfill operator may become alarmed by a laboratory chemical container, even if it contains sucrose. Note that if different types of waste are comingled, though, then the mixture must be treated as hazardous waste, and the cost for disposal of the nonhazardous portion may increase. Also consider the possibility that a hazardous material may be improperly labeled or described as nonhazardous.



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